Baseline Assessment of HACCP Compliance
in the
FSAI/Health Board National HACCP Strategy
2003 Target Premises
Table of Contents
Survey Participants…………………………………………………………. 3
Background………………………………………………………………….. 4
Methodology…………………………………………………………………. 4
Results and Discussion…………………………………………………...... 4
− General Results……………………………………………………… 4
− Analysis by business type …………………………………………. 5
− Barriers to HACCP compliance …………………………………… 7
Conclusion …………..………………………………………………………. 9
Annex I …………………...……………………………………………..…… 11
2
Survey Participants:
EASTERN REGIONAL HEALTH AUTHORITY
Údarás Réigiúnda Sláinte an Oirthir
The Northern, East Coast and South Western Area Health Boards
3
Background
At an international level it is well recognised that HACCP (Hazard Analysis and
Critical Control Point) is an enormously useful tool to ensure the production of safe
food. In Europe it has been enshrined in legislation since 1993.
The Food Safety Authority of Ireland/Health Board National HACCP Strategy
(http://www.fsai.ie/industry/HACCPstrategy.htm ) aims to facilitate an increase in the
adoption of food safety management systems based on the principles of HACCP
within the Irish food industry. Its objectives are to;
1.
2.
3.
4.
5.
6.
7.
aggressively promote HACCP at national and regional level.
demystify the concept of HACCP.
develop a targeted approach to ensuring full compliance with the law
facilitate the development of an enhanced role for the industry in its own
development of HACCP.
develop a consistent approach to implementation and enforcement of HACCP.
develop and implement an accurate measure of the success of the strategy.
In order to focus resources, the National HACCP Steering Committee (consisting of
an Environmental Health Officer (EHO) representative from each of the 10 Irish
health boards and relevant staff members from the Food Safety Authority of Ireland
(FSAI)) is applying the strategy by targeting specific food business types. During
2003, three business types were chosen, namely, hospitals, nursing homes and
hotels. Hospitals and nursing homes were chosen on the basis of the necessity of
serving safe food to those who are most susceptible to infection. Hotels with
function catering were also targeted, given the potential to make a large group of
people ill. Irish hotels have been associated with outbreaks in the past, although it
should be borne in mind that large outbreaks are easier to detect and therefore may
be over represented in the outbreak surveillance statistics, versus smaller outbreaks
or foodborne illness which occurs in the home.
Methodology
The EHOs in the 10 Irish health boards identified over a thousand premises
belonging to these three business types. The businesses were assessed based on
a standard protocol, using the FSAI Guidance Note No. 11 on ‘Compliance with
Regulation 4.2 of the European Communities (Hygiene of Foodstuffs) Regulations
2000 (S.I. No. 165 of 2000)’ (http://www.fsai.ie/industry/Compliance_Aug_02.pdf )
and a standard report form (Annex I). HACCP compliance was assessed by
examining the three major elements of a HACCP system: a) hazard analysis; b)
control of critical control points (CCPs); and c) verification.
Results and Discussion
1. General Results
Overall the results were promising and showed that considerable progress has been
made by there food business types with regard to HACCP compliance. However, as
can be seen in Figure 1, there is still room for improvement, with somewhere in the
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region of only 20% of businesses being considered to be in full compliance with
each of the three elements of HACCP.
Figure 1: Initial assessment of HACCP compliance - All Premises
100%
90%
210
272
172
% in compliance
80%
70%
Compliant
547
60%
50%
647
No evidence
780
40%
Commenced
30%
474
20%
10%
284
141
0%
Hazard analysis
Controlling CCPs
Verification
HACCP compliance stage
Note: the numbers listed in the bar chart are actual numbers of premises
88% of businesses assessed were controlling, or had commenced controlling, the
critical control points (CCPs). However, it appeared that over 10% of businesses,
were controlling CCPs without ever having conducted a hazard analysis. As a
consequence it is possible that these businesses may have points in their process
where a food safety hazard is not being controlled, i.e. points which should be
CCPs. Alternatively they may be controlling points that are not genuine CCPs,
thereby wasting resources.
Unsurprisingly a large number (40%) of businesses were not verifying their HACCP
system. Internationally it is recognised that this element of the HACCP system is
least well understood and therefore rarely implemented properly, if at all.
2. Analysis by business type
Looking specifically at the three different business types and their sub types (Figures
2a, b and c) it can be seen that of the hospitals, voluntary hospitals appear to be
struggling with the three elements of HACCP.
The health board hospitals have made good progress with respect to controlling
CCPs, however there are a number of premises which have not conducted a hazard
analysis which may have consequences for the validity of the CCPs being
controlled. Of the nursing homes, the health board nursing homes appear to have
made more progress with HACCP compliance than either the voluntary or private.
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Figure 2a: Hazard analysis by food business type
100%
% in compliance
90%
123
35
3
3
70%
Compliant
17
60%
50%
305
184
76
15
Commenced
No evidence
15
40%
35
30%
15
20%
10%
4
72
22
80%
127
98
36
0
0%
Hotels
Health
Board
hospitals
Private
hospitals
5
3
Voluntary
hospitals
Health
Board
nursing
homes
Private
nursing
homes
Voluntary
nursing
homes
Premises
Note: the numbers listed in the bar chart are actual numbers of premises
In the case of all three business types, hospitals, nursing homes and hotels, the vast
majority of businesses were controlling their CCPs, even though they may not have
conducted a hazard analysis. Verification of the HACCP system appeared to
present the greatest challenge.
Figure 2b: Controlling CCPs by business type
100%
% in compliance
90%
127
80%
44
3
3
3
70
22
Compliant
70%
60%
50%
25
340
40%
93
17
No evidence
255
15
Commenced
35
30%
20%
10%
88
0%
Hotels
10
Health
Board
hospitals
7
0
Private
hospitals
Voluntary
hospitals
3
29
Health
Board
nursing
homes
Private
nursing
homes
4
Voluntary
nursing
homes
Premises
Note: the numbers listed in the bar chart are actual numbers of premises
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Figure 2c: Verification of HACCP by business type
100%
% in compliance
90%
3
2
18
77
17
80%
250
Commenced
32
16
40%
30%
228
Compliant
152
75
50%
20%
9
13
70%
60%
2
53
No evidence
19
13
149
54
10%
11
0
0%
Hotels
Health
Board
hospitals
Private
hospitals
Voluntary
hospitals
Health
Board
nursing
homes
Private
nursing
homes
Voluntary
nursing
homes
Premises
Note: the numbers listed in the bar chart are actual numbers of premises
3. Barriers to HACCP compliance
Before implementing a successful HACCP system, food businesses must already be
operating to standards of good hygienic practice, by having in place appropriate
prerequisites. For hospitals lack of these prerequisites was identified as the main
barrier to HACCP compliance (Figure 3a).
Figure 3a: Barriers to HACCP compliance in Hospitals
voluntary hospitals
other barrier
private hospitals
poor ownership of externally designed plan
Health Board hospitals
lack of management/owner commitment
staff turn-over
time
cost
lack of in-house HACCP skills
lack of prerequisites
0
5
10
15
20
25
30
35
40
45
No. of audited premises
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Lack of in-house HACCP skills was the key barrier identified for both the nursing
homes and the hotels (Figures 3b and c). While lack of prerequisites was the
second most common barrier for both these business types.
Cost and time were significant barriers for all premises assessed. Worryingly lack of
management/owner commitment was a feature in all three business types. It is
acknowledged that there is a cost and time investment with the design and
implementation of HACCP, but in the long term use of these resources will have a
positive outcome for the food business in more efficient focusing of resources and in
food safety assurance. However, if the legal importance and the safety benefits of
HACCP are not recognised by the owner/manager, then HACCP compliance is
difficult to achieve.
Figure 3b: Barriers to HACCP compliance in Nursing Homes
other barrier
voluntary nursing home
private nursing home
poor ownership of externally designed plan
Health Board nursing home
lack of management/owner commitment
staff turn-over
time
cost
lack of in-house HACCP skills
lack of prerequisites
0
20
40
60
80
100
120
No. of audited premises
Frequently food businesses find themselves without the necessary skills to design
and implement HACCP (a barrier identified particularly in the case of hotels and
nursing homes (Figures 3b and c) but also for hospitals (Figure 3a)) and therefore
call upon an external advisor or consultant to assist. This can work well, provided
the business is involved in the design and implementation of the system and the
staff are sufficiently trained to run the HACCP system in the absence of the
consultant, i.e. business ownership of externally designed HACCP systems or plans.
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Figure 3c: Barriers to HACCP compliance in Hotels
other barrier
poor ownership of externally designed plan
lack of management/owner commitment
staff turn-over
time
cost
lack of in-house HACCP skills
lack of prerequisites
0
20
40
60
80
100
120
140
160
No. of audited premises
Conclusion
Overall the majority of premises assessed had either commenced compliance or
were found to be fully compliant with respect to compliance with Regulation 4.2 of
the European Communities (Hygiene of Foodstuffs) Regulations 2000 (S.I. No. 165
of 2000)’.
Most progress has been made in the area of controlling CCPs.. However 25% of
businesses had not conducted a hazard analysis, therefore even if they were
controlling CCP’s they may have been controlling the wrong ones or may not have
identified others. Unsurprisingly, 40% did not have the verification element of the
HACCP systems in place. This is in line with international findings, as this element
of HACCP is the least well understood and therefore the least well implemented.
In the case of the hospitals, lack of prerequisites was identified as the main barrier to
compliance. In health board owned premises it is not surprising, given the financial
pressures on the overall Department of Health Budget, that this situation may have
arisen, however it can not be allowed to continue. In the nursing homes and hotels,
it was the lack of in-house HACCP skills that was considered to be the principle
barrier.
In summary, the purpose of the National HACCP Strategy is to assist food
businesses (in this case the target groups for 2003) to move towards full
compliance. This initial assessment of the 2003 targeted premises has provided a
baseline against which the effectiveness of the HACCP Strategy can be measured.
This study has revealed the elements of HACCP compliance which these three food
businesses types find most difficult to implement and has identified barriers to
overall HACCP compliance.
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Annex I
ASSESSMENT OF HACCP COMPLIANCE
(I)
Environmental Health Officer: __________________________________________________
Name & address of premises and/or Ref No: ______________________________________
____________________________________________________________________________
Premises type:
Hotel F
*Nursing Home F
*Hospital
F
*Please indicate for hospitals and nursing homes:
Health Board F
(II)
Voluntary F
Private F
HACCP – SUMMARY OF STAGE OF COMPLIANCE
Stage of Compliance
Section
of Regulation 4.2
No evidence of
compliance
Commenced
compliance*
Compliant
A) Hazard Analysis
B) Controlling CCPs
C) Verification
*Note: The classification ‘commenced compliance’ refers to situations where (i) businesses are in the
process of designing and/or implementing a system and where (ii) businesses have an operating
system which does not, in the professional judgement of the EHO, ensure the safety of the food.
(III)
BARRIERS TO COMPLIANCE (please tick the most relevant box(s) where you are
aware of a barrier and expand if you wish)
Lack of prerequisites
Lack of in house HACCP training/knowledge/understanding
Cost
Time
Staff turn over
Lack of management/owner commitment
Poor ownership of a plan designed by an external consultant
Other (please specify) __________________________________________________
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